Carter v. Carter, 43 Fla.L.Weekly D599 (Fla. 5th DCA 2018). Fact former wife failed to include Martyak language on notice of hearing for motion for contempt is not germane if other party attends hearing.

Erlinger v. Fererico, 43 Fla.L.Weekly D6060 (Fla. 1st DCA 2018). Trial court properly denied second motion to recuse based on Judge’s statement wife “does just what she wants”, judge made facial expressions and had “highly questionable rulings in the past”. It is well settled that a judge may form mental impressions and opinions during the course of a hearing. Mere characterizations and gratuitous comments, while offensive to the litigants, do not in themselves satisfy the threshold requirement of a well-founded fear of bias or prejudice. Non verbal expressions do not provide grounds for disqualification.

Albassam v Klob 43 Fla.L.Weekly D509 (Fla. 4th DCA 2018). Trial court affirmed for denying 1.540 motion alleging divorce judgment was void because Wife’s first divorce was not legal This should have been brought up in original divorce.

Lamorte v. Testoni, 43 Fla.L.Weekly D569 (Fla. 4th DCA 2018). Trial court affirmed for not awarding support for special needs child past 18th birthday as issue was not preserved for appeal. However, this does not prevent parent from seeking extension of support pursuant to section 743.07(2), Florida Statutes.